The protocol will take effect once both countries have exchanged ratification instruments and will apply from 1 January of the year following its entry into force
San Marino issued Council Decree No. 120 on 26 September 2025, ratifying the amending protocol to the 2006 income and capital tax treaty with Luxembourg.
Signed on 14 May 2025, the protocol modifies Mutual Agreement Procedure by deleting the sentence stating that the mutual agreement procedure expires at the end of the third year after the case is submitted by the taxpayer.
It will take effect once both countries have exchanged ratification instruments and will apply from 1 January of the year following its entry into force.
Earlier, San Marino’s parliament approved the ratification of the protocol to the 2006 income and capital tax treaty with Luxembourg on 15 September 2025.